We are representing clients in IRS audits under the new BBA partnership audit regime

Davis Polk is representing several clients in IRS audits under the new centralized partnership audit regime mandated by the Bipartisan Budget Act (BBA) of 2015.

Our work includes representing a renewable energy partnership that is disputing a $1 billion imputed underpayment proposed by the IRS from an adjustment with no income or tax effect on the partners.

The BBA partnership audit regime is generally effective for tax years beginning January 2018, and final regulations were issued by the IRS and Treasury in December 2022.

The Davis Polk tax controversy team includes partner Mario J. Verdolini, counsel Christopher A. Baratta and associates Michelle Zhao and Ben Silver. Partners Patrick E. Sigmon and Ethan R. Goldman are providing additional tax advice. All members of the Davis Polk team are based in the New York office. 

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